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Six More Countries Sign FATCA Agreements with U.S.

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Tax Section

The
Treasury Department announced on Thursday that the United
States has signed six more bilateral agreements to implement
the reporting and withholding provisions of the Foreign
Account Tax Compliance Act (FATCA), P.L. 111-147. The
agreements with the Netherlands, Malta, Bermuda, Jersey,
Guernsey, and the Isle of Man bring the number of signed FATCA
intergovernmental agreements to 18.

FATCA requires
foreign financial institutions (FFIs) to report to the IRS
information about financial accounts held by U.S. taxpayers or
by foreign entities in which U.S. taxpayers hold a substantial
interest.

The Netherlands, Malta, Jersey, Guernsey, and
the Isle of Man each signed what are known as Model 1A
agreements, under which FFIs report information about U.S.
accounts to their home governments. Those governments then
report the information to the IRS. These agreements are
reciprocal, meaning that the U.S. government will provide
similar tax information to these governments regarding
individuals and entities from their jurisdictions with
accounts in the United States.

Bermuda signed a Model 2
agreement, under which Bermudan FFIs will register with the
IRS and report the information required by FATCA directly to
the IRS.

The winner of The Tax Adviser’s 2014 Best Article Award is James M. Greenwell, CPA, MST, a senior tax specialist–partnerships with Phillips 66 in Bartlesville, Okla., for his article, “Partnership Capital Account Revaluations: An In-Depth Look at Sec. 704(c) Allocations.”

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